One of the most controversial laws of the last year came into force on 1 January 2013 establishing enforcement measures against individuals involved in the infringement of fundamental human rights and freedoms, and rights and freedoms of Russian Citizens. The Russian Ministry of Foreign Affairs (the “MIA”) has already created a closed list of US citizens whose stay in Russia is undesirable.

Such citizens’ financial and other assets located in Russia will be frozen. Transactions involving their property or investments are forbidden. Moreover, the activities of legal entities controlled by those US citizens on the list will be suspended as well as their authority (membership) on the Boards of Directors or other management bodies of any organisations registered in Russia.

The business of non-commercial organisations also will be suspended if they:

  1. take part in political activities and receive money or other assets on a gratuitous basis from US individuals (organisations) on the MIA’s list;
  2. carry on activities in Russia that threaten Russia’s interests.

The Russian Ministry of Justice is entitled to initiate court action to freeze such organisation’s assets and subsequently decide on whether to allow the resumption of its business.

A US citizen included on the MIA’s list is not allowed to be a member or a head of a Russian, foreign or international non-commercial organisation which participates in any political activity in Russia or its department, subdivision, branch or representative office.

Some other measures have been imposed against US citizens included in the list, such as a prohibition on entering Russia or adopting Russian citizens.

[Federal Law No. 272-FZ “On Enforcement Measures against Those Involved in the Infringement of Fundamental Human Rights and Freedoms, and Rights and Freedoms of Russian Citizens’”, dated 28 December 2012]